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on 22 of those occasions (or within a day or two of the claimed
date for those occasions).2 The total number of miles
petitioners drove the truck for the purpose of acquiring farm
equipment or supplies on those 22 occasions was 2,368.
Petitioners did not present receipts for the actual cost of this
use, but we may apply the standard mileage rate to determine the
allowable deduction.3 The standard mileage rate for 2002 was
36.5 cents per mile. Accordingly, the total allowable expense
for farm-related use of the truck amounted to $864.32.
Petitioners’ mileage log contains three entries pertaining
to automobile maintenance and repair that are corroborated by
bank records, showing purchases of $224.99.4 In addition,
petitioners submitted a credit card receipt for $100 of repairs
to the truck.
2The dates of use that are matched by substantiating
purchases are: Feb. 2 and 18; Mar. 3, 13, 16, and 18; May 6, 7,
and 24; July 5 and 17; Aug. 5, 14 (two purchases on Aug. 14), and
31; Sept. 1, 2, 3 (two purchases on Sept. 3), 16, and 21; Oct. 1
and 10; and Nov. 29.
3The standard mileage rate is a matter of administrative
convenience by which a taxpayer may compute the amount of
deductible automobile expenses using a standard rate rather than
separately establishing the amount of an expenditure for travel
or transportation. Sec. 1.274-5(j), Income Tax Regs., in part,
grants the Commissioner the authority to establish a method under
which a taxpayer may use mileage rates to substantiate, for
purposes of sec. 274(d), the expense of using a vehicle for
business purposes. See Rev. Proc. 2001-54, 2001-2 C.B. 530.
4These dates are: Mar. 13, Mar. 16, and Nov. 29. The
corresponding claimed expenses are $141.79, $69.20, and $14.
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Last modified: November 10, 2007